Alcedo v. State Farm Mut. Auto. Ins. Co.

This declaratory judgment action presents the question whether an automobile insurer must obtain a new writing "signing down" uninsured and underinsured motorist (UM/UIM) coverage from bodily injury liability limits under § 1734 of the Motor Vehicle Financial Responsibility Law (MVFRL)1 when the insured adds another vehicle to the policy. The Pennsylvania Supreme Court has not decided the issue. In a non-precedential opinion, the Third Circuit has held that a § 1734 sign down of UM/UIM coverage continues in effect after bodily injury liability limits are increased. Several district courts…